PRIVACY POLICY

Last Modified: January 3, 2020

Brillini Travels Inc. is a corporation formed pursuant to the Business Corporations Act R.S.O. 1990, CHAPTER B.16 in Canada. Further to our terms of use (www.brillinitravels.com/terms-of-service/) (the “Terms”), this Privacy Policy sets out how we collect, store and use personal information and cookies. Unless otherwise indicated, any capitalized terms in this Privacy Policy have the same meaning attributed to them in our Terms.

By agreeing to our Terms or by using our Website or Service, you consent to the collection and use of personal information in accordance with this Privacy Policy, which we may update from time to time.

If you believe that we have not adhered to this Privacy Policy or would like to request an amendment to personal information being held by us, please contact our Privacy Officer by e-mail sent to [email protected]

PART I: COLLECTION OF PERSONAL INFORMATION

The Personal Information of Other Individuals

To the extent you provide us with, or upload data that includes the personal information of another individual, you represent and warrant that you have that individual’s consent to provide us with their information to use in accordance with this Privacy Policy and our Terms. If you do not have their consent, you agree not to upload or provide us with any such personal information.

To use our Service and have us create a customized Travel Plan for you, we may collect the following personal information:

Full name;

Billing address;

Email address;

Phone number;

The country who issued your passport, and the passport of individuals you will be traveling with;

Other types of raw data relating to how you interact with the Website, for example, your browser information and session duration; and

All other information you voluntarily provide on our Website or as part of our Service.

Social Media Account Login Providers

Where you elect to create an account using a social media account login provider, for example, LinkedIn, Facebook, Google or Twitter, you agree and acknowledge that they may provide us with certain profile and account information to establish your account.

Although we may host their forms on our Website, when you provide your payment details on the Website, you are providing them to PayPal. You acknowledge that our third-party payment processors may have their own agreements which apply to you. While we will not have access to your entire credit card number, we may have access to certain card and payment details such as the name on your card, billing address and card expiration date. If you have questions regarding our payment processor, please contact us.

You may also elect to pay us using an electronic funds transfer or email money transfer directly from your bank.

PART II: THE USE OF PERSONAL INFORMATION

We do not sell your personal information to third-parties. However, we may use personal information to:

Facilitate the operation of the Website and Service, including communicating with you about your travel plans and creating travel plans for you;

Bill and collect money owed to us;

Verify your contact information;

Provide user support or to support and improve our Website and Service;

Communicate with you about services we offer;

Send or display informational and promotional materials, via email. You may unsubscribe from such communications at any time;

Pursue available legal remedies to us and to prosecute or defend a court, arbitration or similar proceeding;

To meet legal requirements or seek legal advice from a lawyer in connection with your use of our Website or Service; and

To enforce compliance with our Terms and applicable laws, rules and regulations.

PART III: THE DISCLOSURE OF PERSONAL INFORMATION

Sharing Personal Information and Content if Required by Law

We may share personal information and any content collected, uploaded or provided to us if required by law, such as in response to a subpoena, court order or other legal process in any jurisdiction. If we are required by law to make any disclosure of your personal information or content, we may, but are not obligated to, provide you with written notice of such disclosure, if permitted by law.

Sharing Personal Information to Cooperate with Investigations and Law Enforcement

Absent a court order, subpoena or other legal requirement to disclose personal information or content in our possession or control, you agree that we may also share personal information and content you upload or which is associated with your account to cooperate with law enforcement authorities in the investigation of any criminal matter if we reasonably believe doing so is necessary or beneficial in protecting your safety, or the safety of any third-party.

Sharing Personal Information with Third-Party Providers

Our suppliers, partners, independent contractors (collectively “Third-Party Providers”) and/or employees, may have access to, or be shared personal information to use in connection with one or more of the purposes for which the information was collected.

Our Third-Party Providers may have access to personal information in providing services to us, or providing you with access to the Website or Service. We may use a variety of Third-Party Providers in order to host our Website and online forms and facilitate their ordinary use, including for example, hosting servers which store personal information.

As of the last revision date of this Privacy Policy, among others, we use the following Third-Party Providers who may have access to, or store your personal information, by virtue of our use of their services:

Our email marketing provider is The Rocket Science Group LLC, a company headquartered in the State of Georgia in the United States, who operate MailChimp. For more information on their privacy practices please see https://mailchimp.com/legal/privacy/.

We also use the following Third-Party Providers for data analytics in connection with your use of our Website and Service, including:

Facebook Pixel, offered by Facebook, Inc. and their affiliated and related entities, which provides us with analytics and insights in to your use of our website. If you are a Facebook user, Facebook Pixel helps us target advertising to you via Facebook, Inc.’s platforms (Facebook and Instagram) based on the various pages you visit on our website. For more information about Facebook Pixel, see https://www.facebook.com/business/learn/facebook-ads-pixel; and

We may update the above list of Third-Party Providers from time-to-time as our Website and Service continue to evolve. Third-Party Providers may have their own agreements and privacy policies on the collection and use of personal information which either we or you provide them.

Your Personal Information May Not Be Stored in Canada

As we may have servers, Third-Party Providers, employees and other parties we share your personal information with in locations both inside and outside of Canada, your personal information may become subject to foreign laws and foreign legal proceedings.

European General Data Protection Regulation

Our privacy practices intend to meet the requirements of the General Data Protection Regulation of the European Union (“GDPR”). As a company that may process the personal information of persons who reside in or who are citizens of the European Union (a “European person”), we have implemented technical and organizational measures to meet the GDPR’s requirements and protect the personal information of European persons. Our technical measures to protect personal information take into account current technology available and the costs of implementing that technology in addition to the nature, scope, context and purposes of the personal information collected and processed. If you have any questions about our technical and organizational measures to meet the GDPR requirements, please contact us.

If you provide us with personal information from European persons, you represent and warrant to us that your personal information collection and storage procedures comply, at all times, with the GDPR. To the extent you provide us with, or, have our Website process any personal information of a European person, you further represent that you have obtained informed consent to transfer their information, internationally, to us. If such consent is subsequently revoked, you agree to inform us immediately. Provided we are a company registered and operating in Canada, you agree and acknowledge that your personal information will be accessed by us in Canada, although it may be stored with Third Party Providers in locations both in and outside of Canada.

Sharing Personal Information if Our Business, Website or Service is Acquired

We may share personal information with our successors (if our business, the Website or Service are acquired by another legal entity) or any assignee of our assets relating to the Website and Service. Disclosure in such circumstances is governed by the Personal Information Protection and Electronic Documents Act, SC 2000, c 5 in Canada.

Disclaimer and Warning About Sharing Personal Information Online

YOU ACKNOWLEDGE THAT WHEN SHARING PERSONAL INFORMATION ONLINE, THERE IS ALWAYS A RISK OF DATA BREACHES, INCLUDING DATA BREACHES IN WHICH THIRD PARTIES UNLAWFULLY ACCESS OUR SYSTEMS, OR THE SYSTEMS OF OUR THIRD-PARTY PROVIDERS, WHICH STORE PERSONAL INFORMATION.

WHILE WE TAKE MEASURES TO PROTECT PERSONAL INFORMATION, YOU AGREE THAT, TO THE FULLEST EXTENT PERMITTED BY LAW, IN NO EVENT WILL WE, OUR AFFILIATES, OFFICERS, DIRECTORS, SHAREHOLDERS, EMPLOYEES, CONTRACTORS, AGENTS, THIRD-PARTY PROVIDERS OR LICENSORS BE LIABLE, HOWSOEVER CAUSED, INCLUDING BY WAY OF NEGLIGENCE, FOR THE LOSS OR THEFT OF YOUR PERSONAL INFORMATION OR ANY DAMAGES CAUSED AS A RESULT THEREOF, SO LONG AS WE WERE NOT DIRECTLY AND GROSSLY NEGLIGENT IN THE PROTECTION OF SAID INFORMATION.

Retention of Your Personal Information

We keep your personal information for as long as it is required for the purpose for which it was collected. There is no single retention period applicable to the various types of personal information collected. Please contact us if you would like to delete any personal information we hold about you following the termination of your account or our Services.

PART IV: Our Use of Cookies

By using our Website or Service, you consent to our use of cookies. This cookies policy explains what cookies are, how we use them and how Third-Party Providers may also use cookies on, or in connection with our Website and Service.

What are Cookies?

Cookies are small text files sent to and automatically downloaded by your web browser (assuming you have cookies enabled) when you visit our Website. A cookie file is stored in your web browser and allows our Website and Third-Party Providers we use to recognize you, track your activity across our and other websites and is usually used in conjunction with logging your internet protocol (“IP”) address.

Cookies can be “persistent” or “session” cookies. Persistent cookies remain on your computer (in your browser files) or mobile device when you go offline, while session cookies are deleted as soon as you close your web browser.

Can you block the use of Cookies?

Most web browsers allow you to disable the use of cookies. However, our Website or certain components of our Website may not operate properly, and you may not be able to access and use our Website if you disable cookies.

Can you delete Cookies once downloaded?

Most web browsers also permit you to delete cookies. This is typically done via your web browser’s settings, which vary depending on which web browser you use. For details on managing cookies settings using:

For any other web browser, please visit your web browser’s official web pages.

How we use Cookies

Our use of cookies is primarily to analyze how you use our Website, for instance which pages you visit most often and where you found our Website online. This helps us better understand your user experience and other statistic which we may use to provide a better user experience in future updates to our Website.